 Sharon Jacobs Harvard Law School

1) Order 719 2) RICE Rules 3) Bigger-picture regulatory questions

 Order 719 (2008)  Order 745 (2011)  Order 755 (2011)  Order 676G (2013)

 Five provisions affecting DR o Ancillary services o Accepting bids from aggregators of retail customer loads o Eliminate deviation charges during system emergencies o Market clearing price should reflect true value of energy during operating reserve shortages o More research on barriers to demand response

 Legal bases for regulation o Ensuring that rates are just and reasonable o Remedying undue discrimination and preference in organized markets  Challenges/pushback o Source of authority o Limits of authority

 Department of Energy  Federal Trade Commission  Environmental Protection Agency

NESHAPs NSPS

 Can operate up to 100 hours per year to participate in demand response emergencies  Can operate up to 50 of those 100 hours to help maintain voltage stability and prevent power supply interruption  Switch to ULSD as of 2015  Reporting requirements beginning in 2015 for larger engines

 Jurisdictional questions  Coordination  Energy vs. environment (?)